March 12, 2010

DENR ADMINISTRATIVE ORDER NO. 06-10

SUBJECT :

Guidelines on the Use of Alternative Fuels and Raw Materials

in Cement Kilns

Pursuant to the provisions of Executive Order No. 192, series of 1987,

Republic Act 6969 otherwise known as the "Toxic Substances and Hazardous and
Nuclear Waste Control Act of 1990" and its Implementing Rules and Regulations,
Republic Act 8749 otherwise known as the "Philippine Clean Air Act of 1999" and its
Implementing Rules and Regulations, and Republic Act 9003 otherwise known as the
"Ecological Solid Waste Management Act of 2000" and its Implementing Rules and
Regulations, the following guidelines on the use of alternative fuels and raw materials
in cement kilns are hereby promulgated for the guidance of all concerned:
SECTION 1.
Basic Policy. These guidelines adhere to the policy of
the government to regulate, use and dispose of hazardous substances and wastes as
stipulated in RA 6969, promote compliance to emissions standards as contained in
RA 8749 and advocate resource recovery as specified in RA 9003.
SECTION 2.
Scope and Coverage. These guidelines set the
registration and permitting requirements, standards and procedures on co-processing
of alternative fuels and raw materials (AFR) for clinker for cement production, which
include among others, the following:
a)

Waste delivery control;

b)

Waste acceptance criteria;

c)

Occupational health and safety requirements;

d)

Co-processing operations;

e)

Emission limits and monitoring;

f)

Documentation and reporting; and

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g)

Enforcement of standards and requirements

SECTION 3.
Definition of Terms. For the purpose of these guidelines,
the following terms are hereby defined:
a)

Alternative fuels refer to non-traditional fuels, such as waste materials,

that provide thermal energy in the production of cement.

b)

Alternative raw materials refer to non-traditional raw materials, such as

waste materials, providing minerals essential in the production of
cement.

c)

Baseline emissions test refers to the measurement of emissions from the

kiln stack of a cement plant operating under normal conditions, in order
to determine compliance to emission limits and emission factors for
trace metals.

d)

Co-processing is the reuse or recovery of mineral or energy content of

waste materials while simultaneously manufacturing cement in a single
combined operation.

e)

EMB refers to the Environmental Management Bureau of the

Department of Environment and Natural Resources.

f)

Emission factor refers to a representative value that attempts to relate

the quantity of a pollutant released to the atmosphere with an activity
associated with the release of that pollutant. The emission factor of each
trace metal is obtained by measuring the quantity of the trace metal
coming out as stack gas and dividing this by the quantity entering the
kiln. An emission factor of 0.05% for a particular trace metal means that
for this particular trace metal, 0.05% of this metal entering the kiln
(coming from the raw materials and/or from the fuels) will appear in the
stack gas. The measurements are done during the stack emissions test.

g)

Hazardous wastes are: (a) substances that are without any safe
commercial, industrial, agricultural or economic usage and are shipped,
transported or brought from the country of origin for dumping or
disposal into or transit through any part of the territory of the
Philippines; (b) by-products, side-products process residues, spent
reaction media, contaminated plant or equipment or other substances
from the manufacturing operations and as consumer discards of

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manufactured products which present unreasonable risk and/or injury to

health and safety and to the environment.
IDTHcA

h)

Healthcare wastes include pathological wastes (such as tissues, organs,

fetuses, bloods and body fluids), infectious wastes and sharps (such as
syringes, scalpels).

i)

ISO 17025 General Requirements for the Competence of Calibration

and Testing Laboratories.

j)

PD 1586 Philippine Environmental Impact Statement (EIS) System.

k)

Pre-processing are operations performed on waste materials in order to

improve its handling characteristics or to maintain the stability of the
cement manufacturing process. For certain wastes, pre-processing is
necessary to transform waste to AFR with defined characteristics that
complies with the technical specifications of the cement plant. These
may involve removal of dirt, size reduction, placing in discrete
containers, mixing with other wastes and/or other materials, or
homogenizing.

l)

Traditional fuels refer to non-renewable energy sources such as coal,

fuel oil, pet-coke and natural gas.

m)

Traditional raw materials refers to limestone, marl, sand, shale, clay,

pyrite cinder, gypsum (natural and synthetic), diorite, silica, tuff,
greywacke, iron concentrate and slag.

n)

Waste materials refer to any material, product or by-product, liquid or

solid that the generator intends to dispose or is required by law to be
disposed of.

SECTION 4.
Hazardous Waste Materials Acceptable for Co-Processing.
A waste material can be co-processed provided it meets the following criteria:
a.

It qualifies as alternative fuel or alternative raw material as defined in

these guidelines;

b.

Its use in the cement kiln complies with applicable environmental

standards provided in RA 8749 and RA 6969;

c.

It should pass waste acceptance criteria based on its calorific value,

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mineral oxides, heavy metal content and other substances, and impacts
on kiln operation, clinker and cement quality as follows:
HScAEC

i.

Heavy metal content and other substances should not exceed the
limits given in the waste acceptance criteria submitted by the
Facility.

ii.

As an alternative raw material, its ash content should be greater

than 50% and its total mineral oxide content should be greater
than 75% (ash basis). Mineral oxide refers to CaO, SiO2, Al2O3,
Fe2O3 and sulfur compounds (expressed as SO3).

iii.

As an alternative fuel, its gross calorific content should not be

less than 2,000 kcal/kg.

iv.

The wastes can undergo pre-processing to comply with

requirement (ii) or (iii).

SECTION 5.
Waste Materials Not Acceptable for Co-Processing. Any
waste materials with impacts on kiln operation, that fails to pass the waste acceptance
criteria, and including the following, shall not be accepted for co-processing:
a.

Health care wastes

b.

Asbestos-containing wastes

c.

All types of batteries

d.

Electronic assemblies and scraps

e.

Explosives

f.

Cyanide wastes

g.

Mineral acids

h.

Radioactive wastes

i.

Unsegregated Municipal solid wastes

The EMB shall review this list every two (2) years or as the need arises.
SECTION 6.

Procedure for Accepting Hazardous Waste Materials for

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Co-Processing. Hazardous waste materials that will be used for co-processing

should pass the following procedure:
1.

The waste material must be properly documented, labeled and

packaged.
acAESC

2.

The delivered waste material shall be subjected to inspection for

contamination and adulteration.

3.

The waste material must be sampled and tested according to the

approved sampling and testing plan.

4.

The waste material upon acceptance shall be weighed and properly

stored.

5.

A transport permit must accompany waste materials that are regulated

under RA 6969.

6.

Waste materials regulated under RA 6969 that do not conform with the
waste acceptance criteria must be rejected and a non-conformance
report prepared and sent to the waste generator. A copy of the report
should be furnished to EMB.

SECTION 7.
Minimum Qualifications of Co-Processing Facilities. All
existing and operational cement plants that intend to engage in co-processing of waste
materials shall:
a.

Have existing personnel, processes and systems that demonstrate its

strong commitment to the protection of the environment, health and
safety. The facility's quality, environmental and health and safety
management system should be ISO (or its equivalent) compliant;

b.

Be compliant with the provisions of the following laws and regulations:

1.

Philippine Clean Air Act (RA 8749)

2.

Philippine Environmental Impact Statement (EIS) System (PD

1586)

3.

Philippine Toxic Substances and Hazardous and Nuclear Wastes

Control Act of 1990 (RA 6969)

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4.

Philippine Mining Act of 1995 (RA 7942) and their

corresponding rules and regulations and

5.

DOLE Department Order No. 16, series of 2001 (Amendments

to Rule 1030 of the Occupational Safety and Health Standards
acADIT

c.

Be capable of controlling inputs and process parameters required for the

effective co-processing of waste materials.

d.

Have an approved protocol/procedure for each type of waste material to

be co-processed.

The co-processing operation of a proposed cement plant shall be incorporated

in its EIS and subject to evaluation and approval of the EMB.
SECTION 8.
Registration Requirements for Co-Processing Facilities.
A cement plant that co-processes waste materials must be registered at the EMB as an
Alternative Fuel and Raw Materials (AFR) co-processing facility. The registration
shall be valid for a period of one (1) year and shall list the types of wastes that the
facility is allowed to co-process. The facility may apply for an amendment of the list
of allowed wastes at any time after registration.
Minimum requirements for registration as an AFR Co-processing facility are:
1.

Official notarized Letter of Request, including an accountability

statement;

2.

New or amended Environmental Compliance Certificate (ECC) of

cement plant;

3.

A baseline emissions test report showing compliance with emissions

regulated by the Philippine Clean Air Act (RA 8749), which includes
National Emission Standards for Source Specific Air Pollutants
(NESSAP) substances and dioxins and furans. The baseline emissions
test shall be conducted by a DENR recognized third-party
laboratory/stack sampling service provider or foreign laboratory with
ISO 17025 accreditation. The EMB may require the test to be
supervised by either the Department of Science and Technology or
other institutions that have the capability to do so as determined by
EMB. The report shall include emission factors for trace metals

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calculated based on the emission test conducted.

4.

Process flow diagram and detailed description of each treatment process

identifying all by-products, end-products and residues and including
pre-processing facility (if applicable);
ICTaEH

5.

Valid Permit to Operate pollution control facilities, Pollution Control

Officer Accreditation Certificate, and an organization chart showing the
names and positions of responsible persons at the co-processing facility;

6.

Storage management plan for waste materials, by-products and

end-products, including pre-processing facility (if applicable);

7.

Photograph(s) of the facilities' processing and storage areas;

8.

Emergency and Contingency Plans including Abandonment Plan;

9.

Financial resources and accountability;

10.

Protocols for each type of waste material that the cement kiln proposes
to co-process. The protocol shall include but not limited to the
following information or data i.e., heating value of the material, raw
material and fuel substitution, feed rate, etc.

11.

The proponent shall pay a processing fee of P5,500.00 in accordance

with prescribed standard costs and fees set by EMB.

SECTION 9.
Operating Conditions and Process Control in
Co-Processing Facility. To ensure safe and effective operations of the
co-processing facility, the following must be observed:
1.

The feed point of waste materials should be properly located in a

cement kiln in accordance with manufacturer/design specifications or
with international standards, specifically:
a.

Waste materials with organic content must be fed only at the

high-temperature (at least 850C) regions of the kiln.

b.

Waste materials containing more than 1% halogenated organic

substances, expressed as chlorine, and must be fed at the main
kiln burner.

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c.
2.

Under no circumstances should waste materials be fed into kiln

until a minimum of 850C is attained at the feed point.

The facility must be equipped with a continuous temperature

monitoring system at the feed point (point where waste materials are
introduced).
caDTSE

3.

Waste materials should only be fed into the kiln when operating
conditions are stable. The facility must be equipped with a control
system to either shut-off or reduce the feed rate of waste materials when
abnormalities or upset conditions in the kiln operations occur. Feeding
of waste materials must be discontinued under any of the following
conditions:
a.

failure of the dust collector;

b.

power failure;

c.

failure of feed point temperature monitoring system;

d.

failure of the CEMS; and

e.

failure of the process equipment

4.

The co-processing facility must be equipped with a continuous

emissions monitoring system (CEMS) capable of measuring the
following parameters: CO, Particulates, VOC or HCl, NOx, and SOx.
Monitoring of VOC shall be required only once the VOC emission
standard has been established by EMB.

5.

Under no circumstances shall a co-processing facility allow feeding of

waste materials to continue beyond four hours of continuous
non-compliance with CEMS monitored emission limit values.

6.

Each facility must develop, implement and communicate a detailed spill

response plan to ensure effective and rapid containment and clean up in
the event of a spill. The facility must be equipped with adequate fire
fighting devices as certified by the Bureau of Fire.

7.

All personnel of the facility directly handling or exposed to waste

materials shall be provided with proper personal protection equipment

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(PPE) in compliance with existing laws, rules and regulations.

SECTION 10.
Emissions Monitoring. Emissions must conform to the
standards specified in the Philippine Clean Air Act (RA 8749) or approved by the
EMB. The emissions must also conform to the internationally accepted level of 0.1 ng
TEQ/NCM for dioxin and furan.
EHaDIC

National Emission Standards for Source Specific Air Pollutants (NESSAP)

Pollutant

Antimony and

Standard
Applicable

Maximum
Permissible

to Source

Limits (mg/NCM)

Any source

Method of
Sampling

Method of
Analysis

USEPA Methods 1

AASb or per

through 5 or 29

sampling method

USEPA Methods 1

AASb or per

through 5 or 29

sampling method

USEPA Methods 1

AASb or per

through 5 or 29

sampling method

USEPA Method 3

Orsat Analysis

or 10

or NDIR

USEPA Methods 1

AASb or per

through 5 or 29

sampling method

50 as HF

USEPA Method 13
or 14 as appropriate

As per
sampling
method

c, d

USEPA Method 11,

15 or 16 as
appropriate

Cadmium
Sulfide Method
or per sampling
method

USEPA Methods 1

AASb or per

through 5 or 29

sampling method

USEPA Methods 1
through 5 or 29 or

AASb Cold
Vapor Technique

101

or Hg analyzer

USEPA Methods 1
through 5 or 29

AASb or per
sampling method

10 as Sb

its Cmpds
Arsenic and

Any source

10 as As

its Cmpds
Cadmium and

Any source

10 as Cd

its Cmpds
Carbon Monoxide

Any industrial

500 as CO

source
Copper and

Any industrial

its Cmpds

source

Hydrofluoric
Acid and
Flouride

Any source other

than manufacture
of Aluminum from

Cmpds

Alumina

Hydrogen Sulfide

i)
ii)

iii)

Geothermal
power plants
Geothermal
Exploration and
Well testing
Any source
other than (i)

100 as Cu

7 as H2S

and (ii)
Lead

Any trade, industry

10 as Pb

or process
Mercury

Nickel and its

Cmpds except

Any source

Any source

5 as elemental Hg

20 as Ni

Nickel Carbonyl
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NOx

1)
2)

Manufacture of
Nitric Acid
Fuel burning
steam
generators
a) Existing
b)

4)

1,500 as NO2

source
New source
i.

3)

2,000 as acid &

NO2 calculated as
NO2

coal fired

ii. oil fired

Diesel powered
electricity

1,000 as NO2
500 as NO2
2,000 as NO2

generators
Any source other
than 1, 2, 3
a) Existing

USEPA Methods 1
through 4 and

Phenol-disulfonic
acid Method or per

Method 7

sampling method

USEPA Methods 1
through 5

Gravimetric per
sampling method

USEPA Methods 1
through 5 or 29

Spectrophometry
or per sampling

1,000 as NO2

source
b)
Particulates

1)

New source

Fuel burning
equipment
a) Urban &
Industrial

2)

500 as NO2

area
b) Other area
Cement Plants

150

200
150

(kilns, etc)
3)
4)

Smelting process
Other stationary

150
200

sources
Phosphorous
Pentoxide

Any source

200 as P2O5

method
Sulfur Oxides

1)

Existing Sources
a) Manufacture
of Sulfuric
Acid and
Sulfonation
b)
c)

2)

process
Fuel burning
equipment
Other
Stationary
sources

New Sources
a) Manufacture
of Sulfuric
Acid and
Sulfonation

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2,000 as SO3

1,500 as SO2
1,000 as SO3
USEPA Methods 1
through 4 and 6 or

As per sampling
method

8 as appropriate
1,500 as SO3

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b)
c)

process
Fuel burning
equipment
Other
Stationary

700 as SO2
200 as SO3

sources
Zinc

Any source

100 as Zinc

USEPA Methods 1

AASb or per

through 5 or 29

sampling method

SECTION 11.
Documentation and Reporting. All aspects of
co-processing waste materials in a cement kiln must be well documented. As such,
documents and records as listed below shall be maintained for at least five (5) years
and be made available for inspection.
1.

2.

Delivery record for each waste material received in the facility must be
maintained for five (5) years. The record of each waste must show the
following information:
a.

Name of waste material and waste ID No. (if hazardous waste)

b.

Category of waste material

c.

Tons of waste delivered

d.

Name of transporter and Transporter ID No. (if hazardous waste)

e.

Name of waste generator and Waste generator ID No. (if

hazardous waste)

f.

Date delivered

g.

Sample Reference No. (if random sampling was performed)

h.

Copy Hazardous Waste Manifest record of each delivery

i.

Copy of transport permit if hazardous

TaCDAH

Daily co-processing operation log sheet must be maintained, covering a

period of five (5) years, showing or attaching the following information:
a.

IDs of waste materials co-processed

b.

Quantity of waste material co-processed

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3.

c.

CEMS printout

d.

Temperature at materials feed point

Laboratory analysis of sample waste materials received in the facility

shall be kept for a minimum of five (5) years.

SECTION 12.
Public Access to Confidential Information on
Co-Processing Facility Records and Reports. Confidential business information,
including but not limited to, related to trade secrets, intellectual property rights and
processes, production/sales figures or processes unique to the cement manufacturer,
or would otherwise tend to affect adversely the competitive position of such cement
manufacturer shall not be made available to the public.
SECTION 13.
Auditing. The EMB shall conduct audits to ensure
compliance of the facility with its co-processing permit and with these guidelines:
a.

The EMB at any time may collect waste samples to verify if it conforms
to waste acceptance criteria. The cost of sample analysis shall be
charged against the account of the facility.

b.

The compliance audit of the facility shall be done at least once a year. A
third party audit may be required by EMB, as it may deem necessary.

c.

The tracking system for these guidelines shall use the system under
DENR Administrative Order No. 04-36.

SECTION 14.
Fines and Penalties. Fines and penalties for violating
these guidelines shall be governed by pertinent provisions given in Philippine Clean
Air Act (RA 8749), Toxic Substances and Hazardous and Nuclear Wastes Control
Act of 1990 (RA 6969), and Environmental Impact Statement System, (PD 1586).
Violation of any provision of these guidelines by a co-processing facility shall
result to suspension or cancellation of Permit to Co-Process, as determined by
DENR-EMB.
HTacDS

SECTION 15.
Separability Clause. If any provision of these guidelines
is declared void or unconstitutional, the remaining provisions hereof is not affected
thereby shall remain in full force and effect. *(1)
SECTION 16.

Repealing Clause. All DENR Administrative Orders that

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are inconsistent with these guidelines are hereby repealed or modified accordingly.
SECTION 17.
Effectivity. This Administrative Order shall take effect
fifteen (15) days after its publication in two (2) newspapers of general circulation and
upon submission of a copy thereof to the Office of the National Administrative
Registry (ONAR) at the University of the Philippines Law Center.

(SGD.) HORACIO C. RAMOS

Secretary
Published in The Manila Standard Today and Malaya on March 17, 2010.
Acknowledgement: ONAR, U.P. Law Center, March 18, 2010.

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Endnotes
1 (Popup - Popup)
*

Note from the Publisher: Copied verbatim from the official copy.

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